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Italian Revenue Agency Ruling no. 131/2025: Clarifications on the nominal tax rate test applicable to foreign dividends

May 28, 2025

With ruling no. 131/2025, the Italian Revenue Agency clarified that, for the purposes of Article 47-bis, paragraph 1, letter b) of the TUIR (Italian consolidated law on income tax), the test of the nominal level of taxation – used to determine whether a foreign tax regime qualifies as preferential in cases of non-controlling shareholdings – must be carried out based solely on the IRES rate (24%), without taking into account either IRAP or withholding taxes applied to dividends payable.

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Mid-year tax decree: new rules on payments, CFC and VAT

With its publication in the Official Journal on 17.06.2025, the decree law approved by the Council of Ministers on 12.06.2025 (no. 84/2025 – the “Decree” or “DL”) comes into effect. The Decree addresses various aspects of tax legislation, introducing amendments designed to simplify, correct, and coordinate recent changes introduced in recent months.

Accreditation by Dubai Chambers for the development of Italian businesses in the GCC

Studio Tributario Deiure has been accredited by Dubai Chambers, Dubai Chamber of Commerce, a key driver of economic development and international business growth in Dubai. Dubai Chambers is an institutional body that maintains an ongoing dialogue with the highest authorities of the United Arab Emirates, playing a strategic role in strengthening the global competitiveness of the Emirate.

Italian Revenue Agency Ruling no. 131/2025: Clarifications on the nominal tax rate test applicable to foreign dividends

With ruling no. 131/2025, the Italian Revenue Agency clarified that, for the purposes of Article 47-bis, paragraph 1, letter b) of the TUIR (Italian consolidated law on income tax), the test of the nominal level of taxation – used to determine whether a foreign tax regime qualifies as preferential in cases of non-controlling shareholdings – must be carried out based solely on the IRES rate (24%), without taking into account either IRAP or withholding taxes applied to dividends payable.

Studio Tributario Deiure with Wellness Holding in the investment in Acqua Filette S.r.l.

Studio Tributario Deiure assisted Wellness Holding, the single-family office of Nerio Alessandri, founder of Technogym, and a group of investors in the acquisition of a minority stake in Acqua Filette S.r.l., a company engaged in the production of ultra-premium mineral water in the luxury segment.

Sustainability reporting – Directive (EU) 2025/794

On 14 April 2025, Directive (EU) 2025/794 of the European Parliament and of the Council was published in the Official Journal of the European Union. This directive amends Directives (EU) 2022/2464 and (EU) 2024/1760 concerning corporate sustainability reporting and corporate due diligence for sustainability purposes. This measure is part of the regulatory simplification package promoted by the European Commission, aimed at reducing the administrative burdens on businesses.

Studio Tributario Deiure with Vergani in the acquisition of Pasticceria Scarpato

Studio Tributario Deiure assisted Vergani, a historic confectionery company that has been producing panettone cakes for over 80 years, in the process of acquiring Pasticceria Scarpato, a company active since 1888 in Villa Bartolomea (VR).

Premial IRES – Measures for approving the 2024 budget

The 2025 Budget Law (L. 207/2024) introduced, applicable only to the tax period following the one in progress on 31.12.2024, a significant tax incentive: the application of a reduced IRES rate of 20% (as opposed to 24%) for corporations that meet specific requirements.

Taxation of Long-Term Cash Bonuses under International Mobility: Clarifications from the Italian Tax Agency

With Ruling No. 81/2025, the Italian Tax Authorities have addressed a case of international taxation regarding the payment of a Long-Term Cash Bonus to an employee who had returned to Italy. The Authorities clarified that taxation must occur in the country where the work activity was effectively carried out during the vesting period, regardless of the beneficiary's tax residence at the time of payment.

The 2025 Reform on the Revaluation of Tax Expenditure regarding Land and Equity Holding

2025 Budget Law (Law no. 207/2024) Paragraph 30 lays out the official framework for the revaluation of tax expenditure regarding equity holding (both listed and unlisted) and land (agricultural and developable), consolidating a provision that has been subject to numerous extensions in the past.

PERSONNEL SECONDMENT – Important information for VAT purposes

Law 166/2024 was published in the Official Journal under number 267 of 14 November 2024, converting Legislative Decree 131/2024 (the so-called EU Infringement Rescue Decree), and contains provisions for the closure of a series of infringement procedures with the European Union, including one concerning the VAT regime for the secondment of personnel.
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Mid-year tax decree: new rules on payments, CFC and VAT

Accreditation by Dubai Chambers for the development of Italian businesses in the GCC

Italian Revenue Agency Ruling no. 131/2025: Clarifications on the nominal tax rate test applicable to foreign dividends

Studio Tributario Deiure with Wellness Holding in the investment in Acqua Filette S.r.l.

Sustainability reporting – Directive (EU) 2025/794

Studio Tributario Deiure with Vergani in the acquisition of Pasticceria Scarpato